Home Highlights June 2013 Year 2013 This

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1. Reopening of assessment u/s 147 - it appears that the AO has recorded to the effect that he could not refer the matter to the Transfer Pricing Officer nor could he...

2. Reopening of assessment u/s 147 - TP Adjustment - The impugned order is not a suo-motu proceedings initiated by the Transfer Pricing Officer under Sub-Section 2B of...

3. TP - Arm's length price - CBDT instruction does not restrict the powers of the AO from making references to the Transfer Pricing Officer after 30th June 2003

4. The High Court held that the Assessing Officer cannot reopen the assessment u/s 147 merely based on a change of opinion. The assessee had fully and truly disclosed all...

5. Issue of reassessment u/s 263, where the Commissioner of Income Tax (CIT) upheld the reassessment as erroneous and prejudicial to the Revenue's interest for verification...

6. Transfer pricing officer (TPO) erred by considering non-associated enterprise (non-AE) revenue and costs while computing transfer pricing (TP) adjustment, contrary to...

7. Transfer Pricing Adjustment - Reference to Transfer Pricing Officer - the aggregate of international transactions was below Rs.15 Crores - AO was not mandatorily...

8. The Principal Commissioner or Commissioner having jurisdiction over transfer pricing matters has been empowered, effective April 1, 2022, to invoke revisionary action...

9. TP Adjustment - Provision of Administrative and Agency Services - Determination of Arm's Length Price (ALP) - allocation of expenses relating to income streams between...

10. The case pertains to the levy of penalty u/s 271G for failure to furnish documents and information u/ss 92CA/92D. The key points are: The Transfer Pricing Officer (TPO)...

11. The High Court quashed the reassessment proceedings initiated by the Assessing Officer u/s 148 of the Income Tax Act, holding it to be a case of "change of opinion" and...

12. If the Transfer Pricing Officer did not agree to the arm's length price shown by the assessee it was open for him to determine the arm's length price by applying one of...

13. Transfer Pricing (TP) adjustments - Transfer Pricing (TP) adjustments - debar of deduction u/s 10A on addition income assessed u/s 92CD as per the Proviso to 92C(4) -...

14. The Appellate Tribunal reviewed a case involving Transfer Pricing (TP) Adjustment for management service fee paid to Associated Enterprises. It was held that the...

15. The Appellate Tribunal (ITAT) considered Transfer Pricing (TP) adjustments related to foreign exchange gains and engineering services. The assessee used Transactional...